This chapter examines how to strengthen openness and whistleblowing in the Dominican government entities, with a particular emphasis on regulatory frameworks and the comprehensive management of reports of wrongdoing. It also offers recommendations to establish whistleblower protection, including by enabling anonymous reporting. The chapter also examines mechanisms for investigating and sanctioning integrity violations, with a special focus on the disciplinary system. It recommends strategic measures aimed at strengthening the fairness, impartiality and independence of these mechanisms, co-operation and information exchange between relevant bodies, and the use and analysis of data to improve their effectiveness and efficiency.
OECD Integrity Review of the Dominican Republic
Implementing a Strategic Vision for Public Integrity and Anti-Corruption
Abstract
Ensuring that corruption and other integrity violations are detected, investigated and sanctioned is an essential duty of governments and is fundamental to establishing public trust. Accordingly, countries with coherent and comprehensive public integrity systems should not only define integrity norms and standards and support and monitor their implementation, but should also ensure compliance with such norms and standards. As the OECD Public Integrity Handbook highlights, enforcement and sanction mechanisms are the necessary “teeth” of any country's public integrity system and are the primary means by which societies can ensure compliance with the rules and deter misconduct (OECD, 2020[1]).
The OECD Recommendation on Public Integrity calls for countries to enable effective accountability through mechanisms for investigating and sanctioning corruption. Investigation and sanction mechanisms should provide appropriate responses to all suspected violations of public integrity standards by public officials and all others involved in the violations. To this end, countries should (OECD, 2017[2]):
Apply fairness, objectivity and timeliness in the enforcement of public integrity standards (including detecting, investigating, sanctioning and appeal) through the disciplinary, administrative, civil, and/or criminal process.
Promote mechanisms for co-operation and exchange of information between the relevant bodies, units and officials (at the organisational, subnational or national level) to avoid overlap and gaps, and to increase the timeliness and proportionality of enforcement mechanisms.
Encourage transparency within public sector organisations and to the public about the effectiveness of the enforcement mechanisms and the outcomes of cases, in particular through developing relevant statistical data on cases, while respecting confidentiality and other relevant legal provisions.
In addition, the timely detection of violations of public integrity standards should be encouraged. Within the context of public integrity, this requires both open organisational cultures that encourage employees, managers and leaders to raise ethical questions, concerns or ideas and prevent misconduct, fraud or corruption, as well as formal reporting mechanisms (OECD, 2020[1]). Regarding the latter, information that comes through reports of wrongdoing is particularly relevant for detecting and investigating misconduct. To support an open organisational culture within the public sector responsive to integrity concerns, countries should (OECD, 2017[2]):
Encourage an open culture where ethical dilemmas, public integrity concerns, and errors can be discussed freely, and where appropriate, with employee representatives, and where leadership is responsive and committed to providing timely advice and resolving relevant issues.
Provide clear rules and procedures for reporting suspected violations of integrity standards, and ensure, in accordance with fundamental principles of domestic law, protection in law and practice against all types of unjustified treatments as a result of reporting in good faith and on reasonable grounds.
Provide alternative channels for reporting suspected violations of integrity standards, including when appropriate the possibility of confidentially reporting to a body with the mandate and capacity to conduct an independent investigation.
This chapter is divided into two sections. The first section is devoted to openness, reporting channels and whistleblower protection mechanisms. The second section looks at the mechanisms for investigating and sanctioning corruption and breaches of integrity. This sequence approaches the issue from a process perspective, with the understanding that whistleblowing is one of the key mechanisms for triggering investigation that may lead to sanctions in any organisation or country.
A holistic approach to public integrity includes measures aimed at fostering openness, in which public officials feel safe to identify and raise ethical questions, concerns or ideas, and at responding to potential violations of public integrity (OECD, 2020[1]). Such openness has three main benefits: first, it can help build trust in the organisation; second, it can help cultivate public officials’ pride, ownership and motivation; and third, it can encourage public officials to raise ethical questions and resolve them before they become damaging to the organisation (OECD, 2020[1]).
At the same time, even in open organisations, public officials may be faced with situations in which they do not feel comfortable raising integrity concerns or violations to their manager. As such, informal engagement must be complemented by formal reporting mechanisms, which enable employees to report misconduct through official channels. Formal reporting mechanisms should also allow for any whistleblower –including private sector employees, citizens and third parties– to report suspected violations of integrity standards. A whistleblower can be a public official who reports suspected misconduct through official channels; a private sector employee who reports concerns within a company or to public authorities; or a third party who brings allegations to law enforcement, government bodies or the media through formal channels.
In this sense, establishing a clear and comprehensive whistleblowing framework is a critical component of an open organisational culture. Effective whistleblowing frameworks have several common characteristics, including clear reporting channels, awareness-raising measures about the available channels, effective review and investigation of reports of alleged wrongdoing and a complementary whistleblowing protection framework to protect and/or provide remedy against any retaliatory action to persons working in the public or private sector who report on reasonable grounds suspected violations of integrity standards (OECD, 2020[1]).
7.2.1. The Dominican Republic could encourage open organisational cultures by supporting leaders to demonstrate their commitment to public integrity and create safe environments for public employees to voice questions, concerns and ideas
An open organisational culture means employees, managers and leaders can regularly engage in conversation with the aim of raising ethical questions, concerns or ideas and preventing misconduct, fraud or corruption. As such, an open organisational culture has the following supportive elements: leadership that is responsive and committed to providing timely advice and resolving relevant issues; and employees who are comfortable raising ethical concerns (OECD, 2020[1]).
Regarding the former, an employee’s willingness to speak up relates positively to perceptions that managers and leaders are transformational and ethical leaders (Avey, Wernsing and Palanski, 2012[3]; Detert and Burris, 2007[4]; Walumbwa and Schaubroeck, 2009[5]). Several tools exist to support leaders in demonstrating their commitment to integrity, including role modelling, communicating about integrity, building peer-to-peer networks, among others. As highlighted in Section 3.4.3 of Chapter 3, the Dominican government could further support Dominican leaders to demonstrate their commitment to public integrity and developing a comprehensive integrity training programme for that purpose. Such a programme could include practical activities to raise awareness of integrity standards, equip managers to handle ethical dilemmas and conflict-of-interest situations (and be able to act as a role model, a moral person) and strengthen leaders’ ability to foster openness and encourage honest, transparent communication (to act as a moral manager).
Leaders’ commitment to openness can also be reflected in their efforts within their organisations to encourage reporting and ensuring a retaliation-free environment. This commitment must be reflected in concrete actions by senior management. In particular, leaders of public entities could:
Assign clear responsibilities and adequate resources for the reception and processing of reports of alleged wrongdoing and ensure internal accountability. Given the cross-cutting nature of management of such reports, responsibility should also extend to relevant units, such as Human Resources and Legal Departments.
Provide effective safeguards against reprisals at all levels. Institutional leadership should communicate unequivocally that retaliation against whistleblowers will not be tolerated and will be subject to sanctions.
Allocate resources to equip personnel responsible for receiving reports of alleged wrongdoing and conducting investigations with clear guidance and predefined measures to address situations involving retaliation or fear of reprisal.
Ensure that personnel in charge of managing reports of alleged wrongdoing possess the required competence and impartiality and are selected based on appropriate professional profiles. These staff should receive regular training on applicable standards, procedures, record-keeping, follow-up, and reporting.
Establish monitoring mechanisms and promote regular reviews of whistleblowing systems.
Additionally, the Directorate General of Government Ethics and Integrity (Dirección General de Ética e Integridad Gubernamental, DIGEIG) could consider an initiative to encourage employees to present measures aimed at improving openness, work processes and well-being. The most promising measures could be selected and tested in the public entity of the winning proposals. Public officials in these entities could be actively engaged in testing and evaluating the selected measures. Successful measures could be scaled up and rolled out across other public institutions. Such an initiative would demonstrate strong high-level commitment to not only listening to employees’ input, but also acting on it meaningfully.
7.2.2. The DIGEIG could publish statistics on the number of reports received and their traceability and improve the information available to both citizens and public officials on reporting channels and procedures
To facilitate the enforcement of integrity standards as well as to investigate and sanction cases of corruption through criminal proceedings or other breaches of integrity through administrative and disciplinary measures, it is necessary to identify suspected cases. One effective way to obtain such information is to ensure the existence of channels through which cases can be brought to the attention of the competent authorities. An effective whistleblowing framework is an essential component of any public integrity system and key to uncovering corrupt practices (OECD, 2020[1]).
In the Dominican Republic, there are several mechanisms and entities responsible for receiving and investigating reports of alleged wrongdoing. The following entities, at different levels and moments, are involved in the processes of receiving reports of alleged wrongdoing, investigating and sanctioning corruption and breaches of integrity in the administrative and criminal spheres: DIGEIG, the Ministry of Public Administration (Ministerio de Administración Pública, MAP), the Office of the Comptroller General of the Republic (Contraloría General de la República, CGR), the Council of the Judiciary (Consejo del Poder Judicial, CPJ), the Public Prosecutor’s Office (Ministerio Público) and within it, the Specialised Prosecutor’s Office for the Prosecution of Administrative Corruption (Procuraduría Especializada de Persecución de la Corrupción Administrativa, PEPCA), as well as the courts of justice.
At the central government level, reports of alleged wrongdoing regarding integrity violations can be received through the following channels:
311 Line (Línea 311), a channel created in 2009, present on the Transparency section of governmental entities websites. The reports of alleged wrongdoing received through this channel are handled by the DIGEIG.
Two specific e-mails, telephone numbers or in person in the DIGEIG premises. Both the email addresses and telephone numbers direct users straight to the DIGEIG’s Access to Information Office, which receives the reports.
In addition, the Directorate General of Public Procurement (Dirección General de Contrataciones Públicas, DGCP) and the National Police (Policía Nacional, PN) also promote reporting by providing citizens with mechanisms to prevent and detect corruption in the areas of competence for which these institutions are responsible.
It is important to have channels for reporting, but more important is to ensure that they are used. The use of a reporting mechanism can depend on several factors. A key dimension is the level of confidence people have in the effectiveness of the State's response to the reports they submit. The OECD Framework on the Drivers of Trust in Public Institutions can help provide clues on how to promote trust in the reporting channel and public institutions involved in the reporting process: (1) responsiveness; (2) ability to address complex and global challenges; (3) integrity; (4) fairness; and (5) openness (OECD, 2017[6]; Brezzi et al., 2021[7]). As such, countries should demonstrate “responsiveness” by ensuring that reports of alleged wrongdoing are followed up, that cases are addressed through appropriate investigative or disciplinary action were warranted and that feedback is provided to the reporting person on the outcome of their report. Responsiveness will be addressed in the section below in more detail. “Fairness” and “integrity” both can be seen as emphasising the relevance of ensuring that all cases are and are perceived to be treated in the same way and without undue political influence, demonstrating that investigations will not focus only on previous governments, for example. Safeguarding credibly the independence of the receiving entity can contribute to signal that all reports will be treated fairly (see Chapter 1 on the need to strengthen the independence of DIGEIG).
Strengthening “openness” requires providing clear information on the channels, the reporting process, the number of reports received, the treatment and follow-up that is being made and on the overall performance of the reporting system. However, currently no reliable data is available on the number of reports received through the different reporting channels or on the follow up that was made to them, which makes it difficult to identify trends, assess the performance of these channels, inform policymaking and being held accountable on the handling of reports. Also, relevant information on reporting channels is missing on the websites of Dominican government entities. While many websites include a link to the 311 Line, there is limited information on the purpose of this mechanism, the reporting process or the overall performance of the system, that is, whether reports actually lead to accountability. Moreover, there is little information on other channels available. For instance, the website of the 311 Line provides only a brief definition of “report” and very limited information on how the DIGEIG handles the reports it receives. It does not offer further guidance on what information should be provided, what whistleblowers can expect after submitting a report, or what other reporting channels may be available. This lack of information may be limiting the use of the channels.
Additionally, according to interviews conducted by the OECD for this Integrity Review, the reports of alleged wrongdoing frequently lack sufficient detail to trigger investigations. In fact, most criminal investigations, and particularly high-profile cases, do not originate from reports by citizens or public officials. Instead, they are typically uncovered through investigative journalism, administrative disciplinary proceedings, unverified public allegations or official communications from oversight and specialised bodies such as the Chamber of Accounts of the Dominican Republic (Cámara de Cuentas de la República, CCRD), the General Inspectorate of the Council of the Judiciary (Inspectoría General del Consejo del Poder Judicial, CPJ), the Anti-Fraud Unit (Unidad Antifraude) of the CGR, the DGCP, and the DIGEIG. This limits the effectiveness of whistleblowing mechanisms as an early detection tool and reduces their contribution to the identification and investigation of integrity violations. The reasons for this observation can be manyfold: there can be a lack of trust in the existing whistleblowing channels or fear of reprisal (see section below). A further reason might be related to the lack of information and guidance on reporting channels and the broader whistleblowing framework.
Considering this, the DIGEIG should start keeping and publishing reliable statistics on the number of reports received through the different channels and their traceability, this is, what happened to these reports (dismissed, investigated, transmitted to responsible authorities, prosecuted, sanctioned etc.). Such statistics are key to inform decision making and to increase accountability. Comprehensive information on the number of reports received, their traceability and their outcomes is essential to assess the effectiveness of the reporting system, identify bottlenecks in the handling of reports, and strengthen public confidence in reporting mechanisms. It could also provide a better understanding of both the quality of the information received and the responsiveness of the State, which can be used to propose improvements.
Furthermore, the DIGEIG should consider providing more and better information regarding the reporting process and the available channels for reporting. One way to do this is by informing citizens of their right to report and encouraging their participation in fostering and overseeing public integrity. Citizens should be informed, in clear and simple language, on a number of aspects that are vital for reporting:
How do misconduct and corruption affect the daily exercise of your rights?
What is corruption and what are other integrity violations?
Why is it valuable to speak out and report alleged wrongdoing?
How can a report be submitted?
What are the channels available to do so?
What information is relevant when reporting?
What happens after reporting: what are the steps involved? What can be expected throughout the process for handling a report and upon completion of such process?
What rights does a whistleblower have?
Is the identity of the whistleblower protected and under what conditions? How is that protection guaranteed?
Is it possible to report anonymously and, if yes, how is that anonymity guaranteed?
Beyond publishing general statistics and information, direct communication with the whistleblowers is key. Once a report of alleged wrongdoing is submitted through any of the available channels, the whistleblower should receive communication on its status, and, where appropriate, on the actions taken by the responsible body and the results achieved. This may include information on investigations conducted, sanctions imposed or organisational measures taken to prevent recurrence of the reported issue. Where a report of wrongdoing does lead to a sanction, it is also important to explain the reasoning behind the outcome, as this helps builds trust in the State’s responsiveness. Conversely, if no investigation is initiated but a faulty procedure or system is corrected, this corrective action and its impact should be communicated to the whistleblower, along with acknowledgement of their contribution. In sensitive cases, protection should be ensured for the reporting person, including formal recognition as a whistleblower, where the legal criteria are met (see Section 7.2.3).
The provision of information on the overall performance of the whistleblowing system could also encourage public trust and greater use of the system. To that end, the DIGEIG could publish statistics and dynamic indicators to enhance transparency on reports of alleged wrongdoing received through all channels, their status, the resulting investigations and the consequences of such investigations. The DIGEIG could also provide disaggregated information to encourage citizen engagement and participation in the oversight of integrity. This may include information on which public entities received reports of alleged wrongdoing and which do not, the type of violations investigated and examples of good practices in entities that demonstrate effective report-handling procedures. In all cases, such information must be presented generically, in a way that fully protects the identity of whistleblowers.
7.2.3. The Dominican Republic could develop a legal, administrative and procedural whistleblowing framework in line with international standards and good practices
Establishing a legal framework for reports of alleged wrongdoing helps ensure that individuals have a reliable mechanism to reporting integrity violations and that the State is held accountable for its effective management. Such a framework should define and organise the relationship between the public and the Dominican public sector in cases of suspected integrity violations. This can be achieved by setting out the procedures, roles and expected outcomes of a reporting process linked to the investigation and possible sanctioning of corruption and violations of integrity. It should ensure safeguards to those who report and protection against retaliation for those who report on reasonable grounds.
Whistleblowing laws should explicitly recognise the contribution of whistleblowers to the protection of public interest. Beyond simply reporting wrongdoing, whistleblowers can provide valuable information that supports the detection and investigation of integrity violations. This is particularly relevant when individuals have direct knowledge of the facts, whether as victims, witnesses, or insiders. Public officials, for example, may be especially well placed to identify irregularities given their familiarity with organisational processes, rules and decision-making structures.
The Dominican Republic has legal provisions that establish the duty of public officials to report misconduct. Specifically, Article 268 of the Code of Criminal Procedure (Law No. 97-2025) obliges all public officials to report offences of public action, and Article 79 of Law No. 41-2008 of Public Service establishes the duty of all public officials in the State, municipalities and autonomous entities to report any illicit and criminal acts of which they are aware of. In addition, Law No. 672-1982, Code of Conduct for Law Enforcement Officials and Law No. 590-2016, Organic Law of the National Police, establish duties to report acts of corruption to one’s immediate superior.
However, the country still lacks a clear legal framework that facilitates whistleblowing, grants protection to whistleblowers and establishes clear procedures to ensure misconduct is investigated and appropriately sanctioned across the public sector. Laws, policies and protective measures for whistleblowers are absent in the existing procedures for receiving reports of alleged wrongdoing and conducting administrative investigations. Moreover, although several government initiatives exist to improve reporting channels and encourage reporting, it is not clear how these channels relate to one another, which channel should be used when or who is “behind” the channel. This also makes it impossible to have clear statistics on the overall number of reports received and how they were processed and with what result.
Considering this, the Dominican Republic could develop a legal, administrative and procedural implementation framework to regulate key aspects of the reporting process and its management, and to ensure the protection of whistleblowers. A report of alleged wrongdoing is not merely the communication of information; it should trigger a structured process of procedural steps aimed at enabling the investigation and, where appropriate, the sanctioning of corruption and other integrity breaches. It is recommended that Dominican law establishes the main stages of the investigation and sanctioning process, together with the core rights, responsibilities and procedural safeguards applicable to the handling of reports. More detailed operational rules and administrative procedures could then be developed through secondary regulations or technical guidance. A whistleblower framework also requires a state body to oversee compliance with the framework, develop policies and technical guidelines and monitor proper accountability in handling reports of alleged wrongdoing. The DIGEIG could assume such stewardship, leaving the responsibility for implementation to the public entities.
In this regard, it is relevant to recall the Draft Organic Law prepared by the DIGEIG establishing the Directorate of Integrity, Transparency and Government Ethics (Dirección de Integridad, Transparencia y Ética Gubernamental, DIGITEG) (see also Chapter 1). This Draft Organic Law explicitly introduces whistleblowers (informantes) and includes a provision that would strengthen whistleblowing management through a dedicated subsystem Once adopted, this subsystem could be developed in line with the recommendations included in this chapter. International experience also offers a range of good practices that could be incorporated into a future legal framework in the Dominican Republic (Box 7.1).
Identify, implement, communicate and maintain whistleblowing channels visible, accessible and secure.
Establish minimum for providing prior information to potential whistleblowers, including public officials, on reporting channels, procedures, protections, and related rights, to ensure that anyone who may file a report of alleged wrongdoing receives clear, accessible, and sufficient information about how the reporting system works before filing a report.
Establish the stages of the process, including a triage stage aimed at examining the admissibility and classification of the report of alleged wrongdoing.
Encourage communication with the whistleblower throughout the investigation.
Regulate the closure of the process, its timeliness, and the communication of its conclusion to the whistleblower.
Establish measures or standards for the confidentiality of information regarding the reports of alleged wrongdoing, the whistleblower and the accused.
Prohibit reprisals against the whistleblower and staff involved in handling the report, put in place protective measures and sanction the perpetrators.
Encourage responsible reporting, i.e. reporting on reasonable grounds.
Set minimum rules for the accountability of public entities for reports of alleged wrongdoing made and the performance of the whistleblowing mechanism over time, including a periodic review of the effectiveness of reporting policies, procedures and channels.
7.2.4. The Dominican Republic could establish an inter-institutional working group to identify and analyse common retaliatory practices with the aim of proposing better targeted protection measures
A key dimension of any whistleblowing framework is the protection of whistleblowers against any retaliation when the report was filled on reasonable grounds. People are often afraid to report any misconduct they have witnessed, been victims of or participated in, as they fear losing rights, being subjected to reprisals by the reported officials or being socially ostracised by their colleagues and peers, among others.
Fear of reporting is very common, and the Dominican Republic is no exception to this trend. Figure 7.1. shows the percentages of citizens in Europe, Latin America and the Caribbean, and the Dominican Republic who fear reprisal for reporting corruption. For Europe, Transparency International's 2021 Global Corruption Barometer shows that 45% of the European Union citizens surveyed fear reprisals (Transparency International, 2021[11]). This perception changes in Latin American and Caribbean countries: 73% of citizens surveyed in this region believe they will suffer reprisals if they report corruption (Transparency International, 2019[12]). With 72% of its citizens responding that they fear reprisals, the figures in the Dominican Republic are similar to the rest of Latin America and the Caribbean, and equivalent to Croatia, the penultimate country in the European comparison.
Question: In this country, can ordinary people report incidents of corruption without fear, or do they risk reprisals or other negative consequences if they report incidents in the fight against corruption?
Sources: For Europe averages: (Transparency International, 2021[11]); for Latin America and the Caribbean averages: (Transparency International, 2019[12]); for the Dominican Republic: (Transparency International, 2019[12]).
As mentioned above, the Dominican Republic currently has no legal framework in place to protect public officials or persons who, based on reasonable grounds, report acts of corruption or misconduct in administrative and judicial proceedings. The absence of specific legislation combined with the lack of institutional guidance and procedures for whistleblowing protection may be undermining the willingness of potential whistleblowers to report, particularly in light of the high levels of fear of retaliation observed in the country.
A practical way to begin the process of establishing the whistleblowing framework, including provisions to ensure protection of whistleblowers, would be to create a working group led by the DIGEIG, established with the specific objective of proposing recommendations for legal reform and implementation of the whistleblowing functional subsystem based on international good practices. The MAP, the Judiciary, the Public Prosecutor’s Office, the General Inspectorate, the PEPCA, the Office of the Comptroller General, and the Chamber of Accounts of the Dominican Republic should participate in this roundtable. The National Police (PN) could also bring its expertise to this working group, as it has an extensive and well-developed system for receiving and managing reports. This task could be carried out by the inter-institutional working group to improve co-ordination and co-operation between entities mandated to detect integrity violations and carry out administrative and criminal investigations recommended in Chapter 1, if it is already in place.
The joint work of these entities should consider international norms or standards on the matter, such as those contained in the OECD Recommendation of the Council for Further Combating Bribery of Foreign Public Officials in International Business Transactions, the European Union Directive 2019/1937, and the United Nations Convection Against Corruption (UNCAC). Other recognised frameworks, such as the draft law to facilitate and encourage whistleblowing and protect whistleblowers of the Organisation of American States (OAS) (OEA, n.d.[13]) could also be used.
This working group should be tasked with the responsibility to deliver specific products, such as recommendations to the President of the Republic for the drafting of legislation, policies and administrative rules on the reception, management and investigation of reports of alleged wrongdoing, whistleblower protection and information in the event of reports of alleged wrongdoing and investigations into misconduct and corruption. Considering the international standards outlined in the previous paragraph, the process of constructing a regulation for the whistleblowers, including provisions to ensure their protection, could consider the good practices summarised in Box 7.2.
Consider the type of protective measures. The best-known measures are the confidentiality of identity and the possibility of anonymous reporting (see next section). However, there are other types of measures that may be appropriate depending on the circumstances and the legal status of the whistleblower.
If the whistleblower is a public official, he or she may fear reprisals at work. They typically consist of obstacles in their administrative or professional career, difficulties in being promoted, being subjected to assignments without regard for the public official's will, being reassigned to areas that may clearly undermine their official position, professional standing, or their safety, or being dismissed from their job. For these cases, some legislations commonly provide for the protection of the whistleblowing public official by means of an interim measure, which prevents their official or employment status from being altered for a certain period of time after a report of alleged wrongdoing has been lodged.
If the whistleblower is a citizen who has witnessed or been a victim of corruption when dealing with a public entity, they may fear that their rights could be affected. In such cases, regulations could consider ensuring impartiality in the processing and resolution of their cases, e.g. by confidentially handling their whistleblower status and assigning the handling of their requests to an organisational unit unrelated to the reported event.
Define protected information. The regulations could govern the legal processing of information and data in administrative and judicial investigations concerning corruption. To this end, they could identify critical information that should be protected, and highlight best practices and lessons learned by some entities with special dedication to the reporting and investigation of integrity violations.
Finally, there is currently no systematic information or data in the Dominican Republic on reprisal practices or on the protection needs of those who report alleged wrongdoing. A specific step to increase the understanding of these dynamics and inform appropriate measures would be to identify the most common forms of retaliation that occur in connection with reporting and investigation processes. In practice, such information is often not found in investigative case files, audits or internal reports, which makes it largely “invisible” to documentary-based analysis. These harmful practices can be identified through qualitative methods such as interviews and focus groups, involving experts in the field, staff engaged in processing reports of alleged wrongdoing and investigation processes, as well as regular users of public services. This information would make it possible to identify, analyse and prioritise retaliatory practices according to risk criteria, and to support the development of reasonable and targeted measures that public bodies could subsequently put in place to protect whistleblowers.
7.2.5. In parallel to the development of the whistleblowing legal safeguards, the Dominican Republic could establish clear policies and regulations to facilitate anonymous reporting and ensure the protection of the whistleblowers’ identity
The purpose of whistleblower protection is to protect individuals from being exposed and retaliated against for disclosing wrongdoing (OECD, 2016[14]). One way to achieve this is to allow for anonymous reporting, particularly in contexts where whistleblowing is socially or culturally sensitive, or where institutional safeguards are not trusted or insufficient to ensure adequate protection (OECD, 2016[14]). Another complementary approach is the protection of whistleblowers’ identities through strict confidentiality measures, ensuring that their identity is not disclosed without their explicit consent (OECD, 2016[14]).
Anonymous reporting remains a debated concept, viewed by some as a crucial channel that enables individuals to come forward, and by others as offering only limited guarantees of protection (OECD, 2016[14]). In any case it can, when combined with robust confidentiality and other safeguards, provide a stronger overall framework to encourage reporting. An experimental study in Indonesia shows that anonymous whistleblowing channels are effective in encouraging whistleblowing particularly when there is a high level of fear of retaliation (Henrico, Wahyudi and Imam, 2022[15]), as is the case in the Dominican Republic. Furthermore, while there is sometimes concern that anonymous reporting will lead to people abusing the channel for false or bad faith reports, statistical evidence from companies in Germany, France, the United Kingdom and Switzerland with anonymous channels shows that these do not lead to such abuse of anonymity (Hauser, Bretti-Reinalter and Blumer, 2021[16]):
“Overall, (...) the fear that whistleblowing systems are being abused on a large scale is not borne out by statistical analysis. At the same time, it is clear that the proportion of abusive reports is no higher among companies that allow anonymous reporting than among those that do not accept anonymous reports” (authors translation)
In the Dominican Republic, the protection of whistleblowers’ identity and the possibility of anonymous reporting are not clearly guaranteed:
Regarding anonymous reports of alleged wrongdoing, the 311 Line requires the provision of personal information before any report can be submitted online, including: passport or identity card number, the name of the person reporting, a telephone number and the province of residence. While some Dominican public entities may accept an anonymous report, this is done in a discretionary manner and is not governed by binding coherent policies, procedures or mechanisms.
On the protection of whistleblowers’ identity, the Dominican Republic currently lacks specific legal or administrative regulations for the protection of information and data in this context. Information in administrative reports of alleged wrongdoing and disciplinary investigations are managed according to organisational practices authorised under general regulations. As a result, officials responsible for receiving reports and handling investigative cases at the administrative level do not operate under specific protocols or procedures for safeguarding information and data. This absence of clear guidance makes it difficult to determine and consistently apply appropriate protective measures.
Considering this, the Dominican Republic could explicitly allow and enable anonymous reporting and provide clear guidelines on the protection of whistleblower’s identity. These measures could be implemented even in advance of the adoption of any pending whistleblowing laws as recommended above, making use of existing government policies and administrative regulations on whistleblower protection within the current legal frameworks. Thus, administrative regulations could help establish safe reporting conditions, including the protection of identity and the acceptance of anonymous reports of alleged wrongdoing under certain conditions.
It should be noted that the DIGEIG already has some practices that can be used as the basis for developing broader measures for all public entities. The Investigations Directorate of the DIGEIG has an action protocol that provides for the confidentiality of the whistleblower's information and the case file, which can only be accessed by authorised personnel responsible for processing or following up on the report of alleged wrongdoing (DIGEIG, 2024[17]). The protocol includes administrative provisions requiring staff to protect the information in the report of alleged wrongdoing, including the identity of whistleblowers. Furthermore, all staff members of the Investigations Directorate are required to sign a confidentiality agreement upon entry into service. The investigation protocol (numeral 21) states that breaches of confidentiality in the context of an investigation constitute a misconduct subject to disciplinary proceedings under Law No. 41-2008 of Public Service.
In addition, the Dominican Republic could consider adopting technological solutions that enable anonymous communication between investigators and whistleblowers, thereby addressing some of the concerns related to anonymity. Examples implemented in Austria, by the Baden-Württemberg police in Germany or by the Ethics and Anti-Corruption Commission in Kenya could serve as inspiration (Box 7.3).
In 2013, the Austrian Federal Ministry of Justice launched a portal to enable individuals to report wrongdoing anonymously. The portal can be accessed via a link on the Ministry's homepage, where further information can be found and downloaded. It is operated by the Central Public Prosecutor’s Office for Combating Economic Crimes and Corruption (CPPOCECC). It is an online anonymous reporting system, ideal for economic crime and corruption investigations. To guarantee anonymity, when setting up a secured mailbox, the whistleblower is required to choose a username and a password. The whistleblower (or “discloser”) may then report anonymously; the investigation authority in turn may make inquiries with the whistleblower, while maintaining his or her anonymity to verify the value of the information. Any relevant reports outside the CPPOCECC remit are forwarded to the competent authority (mostly financial authorities). The anonymity of the information disclosed is maintained using encryption and other security procedures. Whistleblowers are asked not to enter any data that give clues as to their identity and to refrain from submitting a report using a device that was provided by their employer. After submission, the CPPOCECC provides the whistleblower with feedback and the status of the disclosure through a secure mailbox, which also allows for an anonymous dialogue between whistleblower and investigator.
The following description is available on the website in German:
“Particularly with regard to the prosecution of white-collar crime and corruption, new strategies and measures need to be developed in order to increase the effectiveness of prosecution and provide the authorities with the tools they need to fulfil their tasks.
White-collar crime and corruption are often characterised by the fact that the perpetrators are highly secretive and act in a conspiratorial manner. Criminal structures can often only be broken up if those involved who are willing to give evidence are given sufficient incentive to co-operate with the law enforcement authorities.
As a supplement to the leniency programme introduced as part of the criminal law competence package, an internet-based anonymous whistleblowing system was therefore set up at the Central Public Prosecutor's Office for Combatting Economic Crime and Corruption (CPPOCECC) for a trial period of two years, which is particularly suitable for investigations into economic and corruption offences and became operational on 1 January 2016.
This whistleblower system gives the CPPOCECC the opportunity to communicate with an anonymous whistleblower via a mailbox. In contrast to the processing of anonymous reports received by post or other means, the system allows the public prosecutors involved to ask the whistleblower to objectify the value of the information while at the same time ensuring absolute anonymity. Reports objectified in this way can then be used as a starting point for investigations or as a prerequisite for concrete suspicion in order to conduct criminal proceedings.
The whistleblower system enables reports on the following key areas, which are based on the CPPOCECC’s catalogue of responsibilities: Corruption; Economic offences; Social fraud; Accounting and capital market offences; Money laundering (authors translation).”
In the same way, both the state police of Baden-Württemberg in Germany and the Ethics and Anti-Corruption Commission (EACC) in Kenya use the “BKMS® Whistleblowing System” developed with the support of the German Agency for International Co-operation (GIZ). This computerised system allows them to receive anonymous reports and ask the whistleblower follow-up questions through an anonymous mailbox that does not require personal data and prevents the tracing of the sender’s IP address. Both agencies explain the features of the platform and include recommendations to help whistleblowers protect their identity, such as not including any data that could lead to their identification (initials, dates, age, employer, etc.) in their username or report.
Source: (OECD, 2017[18]). For Austria: (Austrian Federal Ministry of Justice, n.d.[19]); for Germany: (BKMS System, n.d.[20]); for Kenya: (EACC, n.d.[21])
Finally, as already mentioned, protecting the identity of whistleblowers requires ensuring the adequate protection of the information contained in reports of alleged wrongdoing. The absence of specific legislation in this area makes it difficult for the Dominican State to provide comprehensive safeguards for the information held in records, databases, reports of alleged wrongdoing and investigative processes.
Nonetheless, the Dominican Republic could adopt documented standards for the protection of information contained in reports of alleged wrongdoing as an interim measure. Such measures generally do not require legal reform and can be implemented while the regulatory framework on whistleblowing is being developed. To this end, the DIGEIG could establish guidelines and practices on information security for reports of alleged wrongdoing to be applied across public entities. These guidelines should be aligned with the future regulatory framework on whistleblowing and international standards on document management and information security. As indicated in Chapter 4, the Dominican Republic would benefit from implementing a Record Management System supported by Information Security Management Systems (ISMS), specifically tailored to whistleblowing, investigation and sanctioning processes, and designed to provide stronger safeguards. The country can also draw guidance from specific rules contained in the European Union Directive 2019/1937, particularly regarding obligations related to confidentiality, the processing of personal data, and record-keeping of reports of alleged wrongdoing (see Table 7.1).
7.2.6. The DIGEIG could establish common procedures for receiving, referring, tracking and monitoring reports of alleged wrongdoing across the Executive Branch, and regularly analyse and publish aggregated data on their handling and outcomes
As mentioned above, in the Dominican Republic, there is currently no public body with a clear government-wide co-ordination role for the whistleblowing framework. This also reflects in the absence of information on the reports of alleged wrongdoing received by the Executive Branch related to breaches of integrity, the corresponding investigative case files, and/or the sanctions resulting from such reports. As a result, there is no consolidated information on the origins of the investigations or the role played by reports in triggering them. Data on reporting in the Dominican Republic are scattered across the different individual public entities, as well as specialised bodies with specific mandates in this area. In addition, there is no systematic sharing of information on integrity-related reports among the many public entities that receive and handle them. Key data gaps also include the number of reports of alleged wrongdoing that lead to disciplinary investigations for first- and second-degree offences.
The Dominican Republic also currently does not clearly communicate whistleblowing as a fundamental objective for the prevention and detection of corruption. The absence of clear communication concerning the relevance of whistleblowing may be undermining to the ownership of public entities in charge of receiving and processing reports. If whistleblowing is not communicated as a clear objective, however, it is difficult to implement policies and establish performance indicators, which ensure articulated action and accountability across government and within individual public entities.
Considering this, the DIGEIG could oversee the whistleblowing system within the Executive Branch. In line with this recommendation, it is also necessary for the DIGEIG to be equipped with the appropriate powers, competencies and resources to lead the whistleblowing system in a comprehensive and effective manner. Regardless of the model adopted, a whistleblowing system typically requires that various public bodies implement related processes. The DIGEIG’s leadership would therefore involve providing guidelines and directives on system implementation and use, as well as on the management of reports of alleged wrongdoing across channels, agencies and public entities, while also collecting, analysing and communicating relevant data to support decision-making and system strengthening.
In particular, the DIGEIG could undertake the following duties related to strengthening whistleblowing in the Dominican Republic:
Develop instructions, monitor their implementation, and provide technical support to public entities (including training) to strengthen whistleblowing, whistleblower management and whistleblower protection in each public entity.
Provide clear guidelines to public entities for the establishment and functioning of report management units, including criteria for the selection of personnel based on competency profiles. The DIGEIG could provide training programmes for the personnel in these units and develop training course programmes to be made available to public entities. The DIGEIG could also provide guidance for managing conflict of interest to personnel of reports management units, in line with the general conflict-of-interest management framework (Chapter 2). It is important to note that the Government Integrity and Regulatory Compliance Commissions (Comisiones de Integridad Gubernamental y Cumplimiento Normativo) or the dedicated integrity units recommended in Chapter 1, should not take on this whistleblowing management role so as not to undermine their preventive role.
Collect, analyse and publish data on reports of alleged wrongdoing, follow-up actions and whistleblower protection to facilitate monitoring and informed decision-making. The DIGEIG could centralise, organise and co-ordinate the collection of records of reports of alleged wrongdoing and investigation case files in all public entities of the Executive Branch, to centralise their organisation and the creation of indicators. In addition, reports of alleged wrongdoing are indicative of potential misconduct and the study of patterns in the administration can feed into integrity risk management and decision-making regarding audit, control and preventive actions. In this sense, the DIGEIG could be a centre of analysis that generates follow-up reports on governmental objectives on whistleblowing and measures the performance of whistleblowing mechanisms in the entities. From a strategic decision-making perspective, the objectives and evaluation criteria in this area should link performance to the achievement of organisational capabilities, processes and outcomes. From a technical-operational perspective, data must be based on reliable records and methods.
Communicate clearly the purpose and objectives of the whistleblowing system to public entities and their leadership. The understanding and implementation of these objectives in each public entity could be supported by instruments that facilitate policy alignment and create incentives for accountability. As a result, the DIGEIG could develop clear guidelines and support for managers. Within these guidelines, reports management units could be required to submit regular reports to management on the level of adherence to the system's objectives, including qualitative and quantitative information on processes and outcomes.
At the same time, public institutions must also assume their responsibility within the reports management system. For example, public managers (which are part of the institutional internal control system) should understand how to properly manage reports of alleged wrongdoing. In this regard, human resources, auditing, finance, planning and legal units should be adequately trained and sensitised to collaborate in the proper functioning of whistleblowing mechanisms and their use to strengthening internal control. Legal units, in particular, are essential for the organisation to ensure that whistleblowing processes uphold principles of fairness and due process for whistleblowers. More broadly, effective reports management requires awareness-raising and training of public officials in general. This is particularly crucial in organisational contexts with high staff turnover, as is the case in the Dominican Republic.
The OECD Recommendation on Public Integrity recommends that countries ensure that enforcement mechanisms provide appropriate responses to all suspected violations of public integrity standards. It also recommends that such responses should address violations by public officials, but also those by all others (persons or entities) involved in the violations (OECD, 2020[1]; OECD, 2017[2]). Public integrity standards are enforced through disciplinary, civil or criminal proceedings, in accordance with the principles of fairness, objectivity and timeliness. In addition, there should be mechanisms for monitoring, co-ordination, co-operation and information exchange between the relevant entities and institutions, within and between each applicable system (OECD, 2020[1]).
This section first briefly touches upon the criminal dimension before focusing on disciplinary mechanisms for breaches of public integrity. The disciplinary regime plays an important role in fostering organisational cultures of integrity in public entities and constitute an essential basis for the investigation and sanctioning of breaches of public integrity.
7.3.1. The Dominican Judiciary and the Public Prosecutor’s Office could commission an independent evaluation of the effectiveness and performance of criminal investigations, prosecutions and adjudications of corruption cases
In criminal matters, the Judiciary, with courts of justice (for the investigation, trial and sentencing stages), courts of appeal and the Supreme Court, and the Public Prosecutor’s Office play a central role in the investigation and sanctioning of corruption offences in the Dominican Republic. Procedural and criminal rules are established in the Code of Criminal Procedure and the Criminal Code. The Public Prosecutor’s Office (Ministerio Público) is an independent and autonomous body. Its independence from the Executive Branch was consolidated through several reforms. Specifically, in 2024, a constitutional reform modified the method of selection of the Attorney General, who is now appointed by the National Council of the Judiciary (Consejo Nacional de la Magistratura) instead of by the Executive, and who must not have had notorious political activity or held an elective political office in the previous years (Medina, 2024[22]; Peguero, 2024[23]). Within the Public Prosecutor’s Office, the Specialised Prosecutor’s Office for the Prosecution of Administrative Corruption (Procuraduría Especializada de Persecución de la Corrupción Administrativa, PEPCA) plays a key role in the fight against corruption.
However, in interviews and meetings conducted for this Integrity Review, areas for improvement in the criminal investigation and sanctioning processes were identified, namely regarding the timeliness and effectiveness of corruption cases. Although initiatives such as the Catch-up Plan (Plan Puesta al Día) and recent cases of administrative corruption show progress, challenges remain. For example, the PEPCA reports that from 2020 to date, it has carried out 9 major operations, leading to final rulings against 36 individuals and the confiscation of over USD 156 million. Nevertheless, multiple sources agree that the investigation and adjudication processes for corruption cases are still slow. Cases take over eight years to resolve, many end without sanctions or with sanctions that fail to deter future crimes. However, available quantitative data were insufficient to assess the timeliness and effectiveness of corruption investigations and prosecutions systematically.
Considering these challenges, the Dominican Judiciary and the Public Prosecutor’s Office could commission an independent evaluation of procedural justice, especially aimed at analysing the performance of the criminal investigation, prosecution and adjudication system for corruption cases. Such an evaluation could yield valuable information about the factors that may be influencing the perceived lack of timeliness and effectiveness of the criminal justice system, and those that could specifically influence corruption cases, identifying procedural, judicial and extra-judicial factors. Such a report could be prepared with the support of international justice agencies or recognised international bodies. On this basis, the Judiciary, the Public Prosecutor’s Office and other actors could propose reforms for the improvement of the legal framework and the updating of judicial criteria on the matter. The Judiciary, the Public Prosecutor’s Office and the wider community would benefit from the involvement of civil society and other institutional actors in the evaluation and proposed reforms.
7.3.2. The Dominican Republic could adopt rules on the disciplinary investigation and sanctioning of integrity violations to ensure these processes are fair, objective, proportionate and timely
Disciplinary systems operate on a permanent and daily basis in public administrations and cover all public officials. Their role is essential within public integrity systems: they directly inform the daily work and activities of public officials and ensure adherence and compliance with public integrity standards and values, defined in legislation, codes of conduct and ethics (OECD, 2020[1]).
In the Dominican Republic, the Law No. 41-2008 on the Public Service establishes the disciplinary framework for public officials. This regulatory framework sets out the duties and obligations of public officials, defines what constitutes a disciplinary offence, establishes a disciplinary procedure for serious or “third-degree” offences, and sets a range of disciplinary sanctions for each type of offence. The Ministry of Public Administration (Ministerio de Administración Pública, MAP), as the governing body for public employment, issues mandatory and binding interpretative opinions on the enforcement of the Public Service Law and its regulations.
However, the disciplinary investigation and sanction mechanisms show significant weaknesses. There are asymmetries in the legal framework, enforcement difficulties and regulatory gaps. These issues may limit both substantive justice (which defines rights, duties and sanctions without unfair privileges for public officials) and procedural justice (which guarantees impartial treatment, access to courts and timely decisions). The OECD Public Integrity Indicators for the Dominican Republic show that Law No. 41-2008 does not include provisions on the presumption of innocence, the right to hearing, the right to legal counsel for disciplinary procedures, nor legal provisions on the right to appeal disciplinary decisions other than dismissal before a judicial body (Table 7.2).
Note: The criteria are from the OECD Public Integrity Indicators’ datasets on “Integrity in justice and disciplinary systems”, indicator “Disciplinary framework for civil servants”.
LAC averages include data from 10 LAC countries: Argentina, Brazil, Chile, Colombia, Costa Rica, Dominican Republic, Ecuador, Honduras, Mexico and Peru.
Source: OECD Public Integrity Indicators, https://oecd-public-integrity-indicators.org/
Going into more detail, the Law No. 41-2008 on the Public Service provides for three types of offences for violations of duties and obligations by public officials: first, second and third degree. The latter are the only ones that may lead to the dismissal of the official. The other two may result in a written warning and suspension from work without pay, respectively. Repetition of a first-degree offence leads to a second-degree offence, and repetition of a second degree-offence leads to a third-degree offence.
The Public Service Law only mandates the opening of a disciplinary investigation in cases of a third-degree offence. However, the legal framework does not clearly define the steps or procedures for conducting these investigations, nor the criteria for doing so. The Public Service Law only mandates that an investigation file be opened. In addition, while the Dominican legislation recognises certain rights of the person under investigation, such as the ability to request access to the file, to defend oneself and to lodge appeals against the sanctioning decision, human resources units do not have clear rules or guidelines on how to facilitate these rights.
For first- and second-degree offences, the Law does not provide a general disciplinary procedure. Instead, it allocates the power to impose sanctions to the immediate supervisor in the case of first-degree offences and to the head of the relevant public body in the case of second-degree offences. In practice, however, sanctions for both first- and second-degree offences may be imposed directly by the immediate supervisor. Since the legislation does not establish an obligation to initiate an investigation procedure for first-degree and second-degree offences -including collecting and disclosing evidence or access to the investigative case file (if any), public officials lack guarantees of defence and due process prior to the enforcement of a disciplinary sanction for first- and second-degree offences.
This lack of procedures and clarity for first- and second-degree offenses may allow for discretionary action by supervisors and comes along with a high risk of misuse. It may be instrumentalised to impose punishments, intimidate and facilitate the dismissal of public officials. This risk arises because supervisors may exercise discretion in classifying first- and second-degree offences. In practice, this can lead to sanctions without proper investigations. Therefore, the weaknesses of the current framework could inadvertently promote a culture of loyalty to hierarchical superiors rather than to the public interest and to the legal rules and procedures.
In practice, the MAP plays an important role in cases of third-degree offences. The MAP maintains a relationship with the human resources units of the public entities, which conduct the investigations, implement the sanctioning measures and document the processes. Human resources units that initiate disciplinary proceedings must inform the MAP of both the opening and closure of each case. In cases which may lead to dismissal, the file must be sent to the MAP for a conciliation hearing. In the latter case, the MAP can verify compliance with due process through its Labour Relations Directorate and Legal Unit. This review of the legality of the disciplinary process is perhaps the only opportunity for a disciplinary process to be reviewed by an external body to verify the legality of the proceedings.
However, the MAP does not yet have an agreed technical-legal instrument on the conditions for a disciplinary investigation and the enforcement of sanctions based on due process, nor it has offered a training programme to staff conducting disciplinary investigations. The human resources units of public entities do not have such guidance either.
Note that, the Decree No. 486-2012 (Article 6) sets out that the Directorate General of Government Ethics and Integrity (Dirección General de Ética e Integridad Gubernamental, DIGEIG) is responsible for receiving reports regarding alleged violations of the ethical and disciplinary regime and the system of prohibitions established in Law No. 41-2008, as well as any other applicable incompatibilities and prohibitions. The DIGEIG can also recommend sanctions and follow up on their application through a technical monitoring committee which includes the authorities responsible for applying the sanctions.
Thus, the Dominican Republic should consider revising disciplinary enforcement and sanction mechanisms to bring them more fully in line with internationally recognised principles of fairness, objectivity and timeliness. The establishment of investigative procedures and safeguards in the disciplinary system is a crucial aspect of this evaluation and reform. The investigation is the procedure that underpins sanctioning decisions, and its regulation should guarantee the minimum necessary to ensure that it is carried out in accordance with due process, facilitating defence and preventing the use of discretion.
For the revision, it may be useful to look at good practices of the National Police. This institution has multiple mechanisms for reporting and detecting risks of inappropriate behaviour, including anonymous reporting and identity protection. It also has a disciplinary process with basic safeguards, managed by specialised control bodies whose personnel receive both internal and international training. In addition, it maintains regularly updated records and statistics, which feed into performance indicators. Lessons learned from this system could help inform improvements to the disciplinary framework for public officials of the Dominican Executive Branch.
Considering the OECD Public Integrity Handbook (OECD, 2020[1]), the American Convention on Human Rights (ACHR) (Articles 8 and 25) and the International Covenant on Civil and Political Rights (ICCPR) (Article 14, fair trial guarantees), the minimum requirements could be as follows:
Respect the right of the accused to the presumption of innocence, considering that any person accused of an offence or crime should be considered innocent until proven guilty, through valid evidence gathering activity conducted by the investigating body.
Notify the accused in a timely manner of the existence and reason for an investigation against him or her.
Have the right to be accompanied by a lawyer at any stage of the investigative and disciplinary proceedings.
Provide them with timely access to information, including documents and evidence on which the accusations are based, to give effect to their right to legal counsel and to defend themselves.
Respect the principle of proportionality, which means that the severity of the sanction imposed should depend on the seriousness of the offence or crime.
Guarantee the right of the accused to lodge appeals in administrative and judicial proceedings.
Every legal rule is developed through subsequent regulatory instruments, which establish operational steps and administrative mechanisms. A legal reform in the Dominican Republic therefore must be followed by administrative developments that define how to address the administrative and operational issues that arise throughout the investigation and disciplinary sanction process. Typically, steps and mechanisms should be put in place to record and document investigation and sanction procedures, safeguard information, communicate with stakeholders and relevant third parties regarding the proceedings, protect whistleblowers and witnesses and protect the honour and privacy of the persons under investigation. These administrative developments are essential to ensure that the legal rules are applied in an operational and uniform manner in the different public entities.
A legal reform could also consider establishing common rules for the investigation and sanctioning of offences committed by public officials, adapting the procedure to the seriousness of the offence. The legal framework of the Dominican Republic recognises the principle of proportionality, which requires that sanctions be aligned with the seriousness of the offence. The principle should apply also to investigations, ensuring compliance with the minimum due process guarantees. Therefore, the legal reform could establish minimum procedural standards for all disciplinary investigations and sanctioning processes, while differentiating procedures according to the seriousness and complexity of the offence. A simplified procedure could be applied to minor offences, while more complex procedures would apply to serious offences. Cases initially treated as minor offences could be reclassified into a more rigorous procedure if evidence emerging from the investigation indicates a higher level of seriousness. This differentiated approach would ensure due process and the right to defence for all public officials, while improving the efficiency and proportionality of disciplinary proceedings.
At present and pending the adoption of such a legal reform, the MAP could develop a regulation or protocol, approved by decree, that establishes a uniform way of conducting investigations of integrity violations that human resources units can use. This regulation or protocol should be framed within the existing Public Service Law. International experience can provide useful inspiration for the Dominican Republic when revising its legal framework for disciplinary enforcement and sanctioning mechanisms. For example, Colombia’s internal disciplinary control system could offer a relevant reference point (Box 7.4).
Colombia’s disciplinary system is a core element of the public officials’ accountability framework, designed to ensure the proper exercise of administrative functions. It is primarily grounded in the General Disciplinary Code (Código General Disciplinario) (Law No. 1952-2019, as amended by Law 2094 of 2021), which replaced the former Disciplinary Code (Law No. 734-2002) while preserving key principles such as legality, due process and the right to appeal.
The Colombian model operates on two levels: a centralised disciplinary authority exercised by the Office of the Inspector General (Procuraduría General de la Nación), and internal disciplinary control (control interno disciplinario) exercised by each public entity. Under the latter, institutions are responsible for investigating and sanctioning their own staff, without prejudice to the overriding authority of the Office of the Inspector General.
The legal framework requires all public entities to establish a high-level internal disciplinary office or unit (oficina o unidad de control interno disciplinario). This body is responsible for conducting preliminary inquiries, carrying out formal investigations and issuing first-instance decisions. A two-tier process must be assured, with appeals typically handled by the appointing authority or a higher-ranking official. Where such an arrangement is not feasible, the Inspector General’s Office assumes this role.
In procedural terms, the disciplinary system follows clearly defined stages: a preliminary inquiry (to establish whether misconduct may have occurred), formal investigation, notification of charges, evidentiary phase, submissions by the parties and a final decision. Throughout, the process must uphold fundamental guarantees, including the right to defence, the ability to challenge evidence, and reasoned decision-making. Disciplinary proceedings are independent of criminal or fiscal actions, reinforcing their nature as administrative sanctions.
As for staffing, these offices must be composed of public officials at least at “professional” level (meaning they should at least have a university degree), with expertise in disciplinary law and the ability to apply the relevant legal framework. Both legislation and case law stress the importance of suitably qualified personnel, given that these roles involve quasi-judicial functions and require strict adherence to due process. Functional independence within the entity is also essential to prevent conflict of interest.
Finally, the Administrative Department of the Civil Service (Departamento Administrativo de la Función Pública) has developed tools to support implementation of the disciplinary system. These include:
Organisational Guidelines for the Structuring of Internal Disciplinary Investigation and Adjudication Units (Circular 100-002 of 2022),
Institutional transformation toolkit for internal disciplinary control, to be accessed here.
Source: Adapted from (DAFP, 2022[24])
7.3.3. The Dominican Republic could strengthen procedural safeguards to strengthen the objectivity of public officials responsible for disciplinary proceedings and build capacities to promote their professionalism
The OECD emphasises the relevance of applying fairness, objectivity and timeliness in the enforcement of public integrity standards (including detecting, investigating, sanctioning and appeal), across disciplinary and administrative processes (OECD, 2017[2]). Objectivity is closely linked to independence, which “guarantees every person the right to have their case decided in a fair trial, based on legal grounds and evidence, and free from improper influence” (OECD, 2020[1]). Therefore, any kind of enforcement actions, including disciplinary ones, should only be taken based on the law, and those enforcing the law should act objectively. In disciplinary proceedings, at least at the first instance level, decisions are usually taken by administrative bodies, which do not have the same safeguards for independence as the judiciary. Since the members of those disciplinary bodies are not judges but civil servants, procedural safeguards should be in place to guarantee that their actions are free from internal or external influence, as well as from any form of conflict of interest (OECD, 2020[1]).”
The current disciplinary system for public officials in the Executive Branch lacks procedural safeguards for objectivity. First, there is currently no clear established profile defining required background and competencies for public officials responsible for disciplinary proceedings. Second, most public officials working in human resources units, that usually are responsible for disciplinary proceedings, do not receive legal training and there are no guidelines on disciplinary procedures (Table 7.3). Exceptionally, for example in the DIGEIG and the Office of the Comptroller General of the Republic (Contraloría General de la República, CGR), training has been provided on an ad-hoc basis, outside the framework of ongoing training programmes, leveraging collaboration agreements and international co-operation projects. Third, not all personnel responsible for disciplinary proceedings are selected based on objective, merit-based criteria (particularly senior-level positions). Finally, personnel responsible for disciplinary proceedings do not receive timely and regular training in managing conflict-of-interest situations.
Note: The criteria are from the OECD Public Integrity Indicators’ datasets on “Integrity in justice and disciplinary systems”, indicator “Integrity safeguards for the application of disciplinary frameworks for civil servants in practice”.
LAC averages include data from 10 LAC countries: Argentina, Brazil, Chile, Colombia, Costa Rica, Dominican Republic, Ecuador, Honduras, Mexico and Peru.
Source: OECD Public Integrity Indicators, https://oecd-public-integrity-indicators.org/.
Therefore, to strengthen objectivity of the personnel in charge of disciplinary proceedings, the MAP should consider establishing adequate safeguards, which could include:
Establishing a specific job profile, defining competencies that enable public officials dealing with disciplinary proceedings to carry out processes with regulated procedures, ensuring investigative effectiveness, due process and proper documentation of all investigative actions, for example. This profile would provide objective selection criteria based on merit and could guide public entities to recruit or identify from among their personnel employees with sufficient experience and training to work on disciplinary proceedings.
Requiring that only career civil servants can be hired to work on disciplinary proceedings to ensure that the public officials enter through public competition and have guaranteed job stability. The MAP could participate in the selection processes of these public officials and oversee compliance with recruitment rules and guidelines. In addition, the Government could consider creating the position of “disciplinary officer”, as a specific type of public employment, subject to the general rules, but with duties and rights commensurate with the importance of this role.
Establishing mandatory training programmes for public officials working on disciplinary proceedings. Cross-cutting training programmes could be implemented, for example, on investigation standards, the handling of reports and files, procedural safeguards, protection of information and investigation techniques. In addition, in co-operation with the DIGEIG, training and guidance on managing conflict of interest could be provided, with practical examples from situations that can arise during disciplinary processes (see also Chapters 2 and 3).
Additionally, international experiences could provide inspiration for the Dominican Republic. For example, Brazil’s legal requirements for disciplinary officials could be a good reference point (see Box 7.5).
Finally, in the context of establishing the whistleblower protection framework recommended in the previous section, it should be ensured that protection mechanisms will also include public officials working on disciplinary proceedings who may be faced with threats and coercion in the exercise of their duties. Indeed, international good practice advises that whistleblowers, witnesses and investigators should be protected, especially when the nature and seriousness of the administrative or criminal offence warrant such safeguards.
Brazil’s federal disciplinary system is governed by Law No. 8112-1990, complemented by Decree No. 5480-2005 and regulations issued by the Office of the Comptroller General (Controladoria-Geral da União, CGU), including Normative Ordinance CGU No. 27-2022, as amended by Ordinance No. 123-2024.
Within this framework, disciplinary activities are co-ordinated through the Federal Corruption Prevention and Disciplinary System (Sistema de Correição do Poder Executivo Federal, SISCOR). Sectoral correction units (unidades setoriais de correição) located in each federal entity are responsible for managing disciplinary matters, including receiving allegations, conducting preliminary assessments, and initiating formal proceedings. These units operate under the technical guidance and supervision of the CGU, which acts as the central authority, issuing standards, consolidating information, and promoting consistency across the system.
Formal disciplinary proceedings, such as processos administrativos disciplinares (PADs), are conducted by ad hoc disciplinary commissions (comissões de processo disciplinar). These commissions are tasked with establishing the facts of each case, gathering evidence, ensuring due process (including the rights of defence and adversarial proceedings), and producing a final report with recommendations. The authority to impose sanctions rests with the competent appointing authority, based on the commission’s findings.
The legal framework establishes specific technical and professional requirements for those responsible for disciplinary functions. Members of disciplinary commissions must be serving federal public officials, typically appointed from within the same entity, and are expected to possess the impartiality, integrity, and technical capacity required to conduct investigations. They must not have conflict of interest in the case and are required to follow strict procedural rules to safeguard due process.
In addition, the heads of sectoral correction units must hold a higher education qualification and be permanent federal public servants or employees (or eligible retired officials), including those with a background in law or in the Finance and Control career. Their appointment is subject to prior review by the CGU, and they are generally designated for fixed terms. While performing correctional functions, these officials retain all rights and benefits of their substantive posts.
Overall, Brazil’s disciplinary system combines clearly defined procedures, institutional responsibilities, and professional requirements aimed at ensuring fairness, consistency, and accountability in the handling of misconduct cases across the federal administration.
Source: Adapted from (Government of Brazil, 1990[25]; Government of Brazil, 2005[26]; CGU, 2022[27]; CGU, 2024[28])
7.3.4. The MAP should publish comprehensive statistics and produce regular reports on disciplinary proceedings and investigations, regardless of the seriousness of the offence, and share this information with other enforcement actors and with the public
The various types of enforcement systems (disciplinary, administrative, civil and/or criminal) each consist of stages and procedures involving several actors. In the Dominican Republic, the Chamber of Accounts (Cámara de Cuentas, CCRD), the DIGEIG, the Directorate General of Public Procurement (Dirección General de Contrataciones Públicas, DGCP), the MAP, the Anti-Fraud Unit of the CGR and the PEPCA play a role in reporting, investigating and sanctioning integrity violations. However, the information gathered during this Integrity Review shows a general lack of co-ordination between them, where one of the weakest aspects is the exchange of information. Indeed, beyond the legal communications regarding acts of misconduct required to trigger the start of proceedings or to advance to a stage within the investigative or sanctioning proceedings, these and other bodies do not have established mechanisms for co-ordination, co-operation and exchange of information.
To this end, Chapter 1 recommended the creation of an inter-institutional working group dedicated to promoting co-ordination and co-operation between the competent bodies dealing with administrative and criminal investigations. This group, for example, could elaborate protocols for the exchange of sensitive data and information on all investigations, including between administrative and criminal investigation bodies, discuss the typology of cases and developments in corrupt practices and breaches of integrity, thus helping to make decisions on the allocation of resources for analysis, prevention and investigation. The quality of the information and data exchanged could improve over time, leading to analysis of key issues and better strategic solutions.
In addition to improved co-ordination and co-operation, oversight of the disciplinary system should be improved. In the disciplinary system, the dispersion of cases throughout the Public Administration makes it highly desirable to have a body that technically co-ordinates the investigative function and oversees the implementation of the disciplinary system, including the management of its data. Currently, however, the MAP, the governing body for the public service and the natural counterpart of the human resources units, does not maintain comprehensive records of disciplinary cases across public entities. The MAP only has access to case file information in instances involving serious offences, which represent a minority of cases. In addition, the MAP does not have access to information necessary to maintain a centralised record of the enforcement of disciplinary sanctions, such as the five-year disqualification applied to dismissed public officials. This fragmentation limits the traceability of disciplinary actions and reduces the visibility of outcomes. As a result, the consequences of investigation and sanctioning process remain partially obscured, constraining the ability of competent authorities to oversee institutional performance and monitor the effectiveness of human resources units in this area.
The MAP could contribute to a better understanding of the performance of the disciplinary system by recording, documenting and reporting on ongoing and completed investigative processes, regardless of the seriousness of the offence. To this end, the Dominican Republic could instruct the authorities of all public entities of the Administration to periodically submit to the MAP information on ongoing and completed investigative processes, as well as the updated public service status of public officials in their agencies. Based on this information, the MAP could maintain comprehensive statistics and produce regular reports on disciplinary proceedings and investigations to be shared with the DIGEIG and other enforcement actors. These reports could be made public to strengthen transparency and accountability, while safeguarding personal data.
Moreover, the information could be analysed to detect patterns and recurring cases for preventive purposes, using these insights to design guidelines or training programmes that address the most common gaps. To support these efforts, the Dominican Republic could consider implementing technological tools for case management. The OECD Public Integrity Indicators show that the Dominican Republic currently does not use an electronic case management system to manage disciplinary cases and proceedings (Table 7.4). Today, there is a wide range of software specially designed to streamline and automate case management within organisations. A technological platform would centralise the organisation and follow-up of cases, record proceedings and back up information and documents. It would also facilitate monitoring, communication, co-ordination and collaboration between the responsible personnel. The MAP would benefit from a case tracking system to monitor the performance of disciplinary enforcement and sanction mechanisms in public entities. It would also facilitate the communication of technical guidelines and support the recording of proceedings and documentation of cases processed, facilitating the subsequent audit or review of proceedings.
Note: The criteria are from the OECD Public Integrity Indicators’ datasets on “Integrity in justice and disciplinary systems”, indicator “Integrity safeguards for the application of disciplinary frameworks for civil servants in practice”.
LAC averages include data from 10 LAC countries: Argentina, Brazil, Chile, Colombia, Costa Rica, Dominican Republic, Ecuador, Honduras, Mexico and Peru
Source: OECD Public Integrity Indicators, https://oecd-public-integrity-indicators.org/.
The incorporation of technology into disciplinary investigation and sanctioning processes is a process of both technological and cultural change and will create new needs as its level of maturity increases. The disciplinary system in Brazil is a good practice in this area (Box 7.6). In a first stage, the needs of the disciplinary investigation and sanction mechanisms should focus on guaranteeing communication and access to information between public entities and the DIGEIG and the MAP, to progressively incorporate process management, alerts, process and task automation and real-time collaboration.
The National Disciplinary Board in Brazil, established under the remit of the Office of the Comptroller General of the Union (Controladoria-Geral da União, CGU), is responsible for overseeing the implementation of the disciplinary system of the centralised federal executive branch: the Sistemas Correcionais or SisCor. The activities of the SisCor are related to the investigation of wrongdoing by public officials and the enforcement of applicable sanctions. The SisCor is endowed with legal powers to supervise and correct any ongoing disciplinary proceedings and to apply sanctions through its employees in the central department and 240 sectional entities located within federal agencies (corregedorias seccionais).
One of the pillars of the co-ordination function of the CGU is the Disciplinary Proceedings Management System (Gestão de Processos Disciplinares or CGU-PAD), software that allows information on disciplinary proceedings established in public entities to be stored and made available quickly and securely.
With the information available in the CGU-PAD, public managers can monitor and control disciplinary processes, identify critical points, create risk maps and establish guidelines for preventing and tackling corruption and other breaches of an administrative nature.
Source: (OECD, 2020[1])
7.3.5. To produce reliable data for integrity policymaking, the DIGEIG should promote a strategic initiative to improve the evidence base on investigations and sanctions
Data can support the strengthening of public integrity systems by providing an empirical basis to identify and assess integrity risks. This includes data on enforcement and sanctions. The systematic analysis of such data enables institutions to better understand patterns of non-compliance, supporting a shift from reactive responses towards more proactive and risk‑based oversight. In an increasingly data-rich environment, this allows for efficiency gains through greater automation, more consistent integrity checks, and targeted prevention approaches, treatment and mitigation policies.
The effectiveness of the use of data analytics depends on the availability and quality, interoperability and governance of the underlying data. Information on enforcement and sanctions in the Dominican Republic is usually found in administrative records, in paper form, but and sometimes also in digital format. Moreover, this data is often fragmented across systems and lacks interoperability, preventing its easy exchange and reuse without further processing. Sometimes, as mentioned in the previous section for data on disciplinary cases and sanctions, information is incomplete or lacking completely. Ensuring data quality, including completeness, consistency and timeliness, as well as improving data integration and accessibility across institutions, is therefore essential. Without adequate data governance and preparation, the effective use of data analytics in integrity and anti-corruption efforts remains limited. Therefore, the DIGEIG could encourage the Government of the Dominican Republic to further align its digital transformation agenda with public integrity objectives. While the country has made progress, increasing the number of public entities with institutional website and the digitisation of various public sector procedures, adopting a Digital Agenda and recently approving a VI Action Plan to the Open Government Partnership 2024-2028 including commitments on open justice, opportunities remain to more explicitly address integrity considerations into these initiatives. At present, public integrity is not included among the areas to be strengthened digitally, and enforcement and sanction mechanisms continue to face a lack of adequate technological support.
Concretely, the Dominican Republic could include the technological strengthening of investigation and sanction mechanisms, including oversight, guidance, case management and accountability, among its strategic integrity objectives, e.g. in the context of the first national integrity strategy currently being elaborated (see Chapter 1).
Within this broader effort to strengthen the digital foundations of public integrity, the Dominican Republic could also address interoperability across public sector information systems. Interoperability channels for the detection and investigation of corruption could facilitate access to the relevant data of individuals and companies for investigation purposes while respecting minimum protection guarantees. Therefore, the use of interoperability should be restricted to serious and qualified cases, intended for administrative or criminal investigation, and where the personnel accessing the information is obliged to safeguard it and ensure its secrecy. There must be a basis of legal, functional and organisational security that safeguards personal data and prevents misuse of such information, while making enforcement and sanction mechanisms more effective.
Furthermore, as a longer-term objective once reliable statistical data on sanctions is publicly available, the DIGEIG could gather and provide this information on an online portal. These statistics could include disciplinary and criminal sanctions and could be disaggregated by sectors and public entities. Having this information available in one place promotes transparency and disaggregated indicators would make sectorial and institutional responsibilities visible, foster ownership of the results and allow for public accountability. In Colombia, for example, the government provides data on criminal, disciplinary and fiscal sanctions related to corruption and integrity violations through the Anti-corruption Portal of Colombia (Portal Anticorrupción de Colombia, PACO).
In short, by laying the foundations for facilitating the flow and exchange of enforcement and sanction data, strengthening data governance and interoperability and by promoting transparency and collaboration, the Dominican Republic could significantly enhance its capacity for evidence-based decision-making in public integrity.
Strengthening openness and whistleblowing
The Dominican Republic could encourage open organisational cultures by supporting leaders to demonstrate their commitment to public integrity and create safe environments for public employees to voice questions, concerns and ideas.
The DIGEIG could publish statistics on the number of reports received and their traceability and improve the information available to both citizens and public officials on reporting channels and procedures.
The Dominican Republic could develop a legal, administrative and procedural whistleblowing framework in line with international standards and good practices.
The Dominican Republic could establish an inter-institutional working group to identify and analyse common retaliatory practices with the aim of proposing better targeted protection measures.
In parallel to the development of the whistleblowing legal safeguards, the Dominican Republic could establish clear policies and regulations to facilitate anonymous reporting and ensure the protection of the whistleblowers’ identity.
The DIGEIG could establish common procedures for receiving, referring, tracking and monitoring reports of alleged wrongdoing across the Executive Branch, and regularly analyse and publish aggregated data on their handling and outcomes.
Strengthening the investigation and sanctioning of integrity violations
The Dominican Judiciary and the Public Prosecutor’s Office could commission an independent evaluation of the effectiveness and performance of criminal investigations, prosecutions and adjudications of corruption cases.
The Dominican Republic could adopt rules on the disciplinary investigation and sanctioning of integrity violations to ensure these processes are fair, objective, proportionate and timely.
The Dominican Republic could strengthen procedural safeguards to strengthen the objectivity of public officials responsible for disciplinary proceedings and build capacities to promote their professionalism.
The MAP should publish comprehensive statistics and produce regular reports on disciplinary proceedings and investigations, regardless of the seriousness of the offence, and share this information with other enforcement actors and with the public.
To produce reliable data for integrity policymaking, the DIGEIG should promote a strategic initiative to improve the evidence base on investigations and sanctions.
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